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Article 4 of the Market Surveillance Regulation (EU) 2019/1020 states that products can only be sold in the European Union if there is an economic operator established there. This can, for example, be an EU manufacturer or importer.
However, non-EU companies cannot function as economic operators, and therefore need an authorised representative (EU AR) that is established in the EU.
In this guide, we explain how this works in practice and what the consequences can be if you don’t have an authorised representative.
Related Articles
1. Authorised Representatives under the General Product Safety Regulation
2. List of European Authorised Representative Companies 2025
3. Responsible Persons under the General Product Safety Regulation
Note 1: This guide does not cover authorised representative requirements concerning medical devices. We have a separate article on this topic here.
Note 2: This article was updated to reflect the fact that the GPSR now extends the EU Authorised Representative requirements to other consumer products. When this guide was initially published, this was only the case for products that required CE marking.
Content Overview
What is an EU authorised representative?
An authorised representative, in most cases, acts on behalf of non-EU companies selling to consumers in the EU. An authorised representative must be a legal entity registered in an EU member state, and they must perform the following tasks, as stated under Article 4:
Verify documentation
1. Verify that the EU declaration of conformity or declaration of performance and technical documentation have been drawn up.
2. Keep a record of the declaration of conformity or declaration of performance at the disposal of market surveillance authorities for the period required by that legislation and ensure that the technical documentation can be made available to those authorities upon request*
*Normally 10 years.
Note: This means that non-EU sellers must provide a full set of compliance documents to the EU authorised representative.
Communicate with national market surveillance authorities
1. Provide the national market surveillance authorities with all information and documentation necessary to demonstrate conformity. This can include the following:
- Test reports
- Risk assessment
- Product labels
- Packaging labels
2. When having reason to believe that a product in question presents a risk, informing the market surveillance authorities thereof.
Non-compliance action
Cooperating with the market surveillance authorities, including following a reasoned request making sure that the immediate, necessary, corrective action is taken to remedy any case of non-compliance.
Product packaging information
The following information must be affixed on the product packaging:
1. The company name of the EU authorised representative.
2. The postal address of the EU authorised representative.
Summary
In short, the EU authorised representative requests and verifies documentation from the seller demonstrating that their products are compliant. As needed, they also communicate with the national market surveillance authorities in case they take action against the products due to compliance issues.
Note that the Product Liability Directive from 2025 also states that authorised representatives are responsible for vetting documents. As such, they cannot merely rent out their company name and address in exchange for money.
How does the process work?
Here is an example of how the process can work:
Step 1: Contact an EU authorised representative and provide the following information for each SKU you intend to sell in the EU:
- Product name
- Model/article number
- Applied EU regulations/directives (if you have this information)
Step 2: Obtain a quotation from the EU AR
Step 3: If you accept, you will then proceed to sign the EU AR service agreement
Step 4: Once signed, you will need to submit compliance documentation to the EU AR
Step 5: The EU AR will review your documents and may request additional information
Step 6: Once completed, the EU AR name, address and contact details can be affixed to the labelling and accompanying documentation (which also concludes the process).
Which companies need an EU authorised representative?
Article 4 of the Market Surveillance Regulation states that an economic operator listed below must be based in the EU:
(a) a manufacturer established in the Union;
Note: This must be an EU company.
(b) an importer, where the manufacturer is not established in the Union;
Note: This must be an EU company.
(c) an authorised representative who has a written mandate from the manufacturer designating the authorised representative to perform the tasks set out in paragraph 3 on the manufacturer’s behalf;
Note: This is the only option available for non-EU companies.
(d) a fulfilment service provider established in the Union with respect to the products it handles, where no other economic operator as mentioned in points (a), (b) and (c) is established in the Union.
EU companies are economic operators, while non-EU companies need an economic operator to sell there.
Examples of companies that need an EU authorised representative
1.Non-EU cross-border e-commerce sellers selling B2C to consumers in the EU
2. Non-EU Amazon sellers shipping to consumers in the European Union
3. Non-EU manufacturers selling directly to consumers in the EU
Examples of companies that do not need an EU authorised representative
1. EU manufacturers
2. EU importers
3. Non-EU companies selling directly to businesses in the EU (i.e., importers or manufacturers).
Is it mandatory to sign with an EU authorised representative?
Yes, it is mandatory to have an authorised representative if you are established outside the EU and sell products directly to consumers.
The customs authorities have the right to seize and destroy incoming shipments without an EU authorised representative address. In practice, this can result in the following for non-EU companies selling without an EU authorised representative:
1. They can no longer sell through Amazon FBA.
2. They cannot ship from fulfilment centres (and could possibly face issues with freight forwarders at some point).
3. They must deal with a higher number of failed shipments (that the customers never receive, as the package is seized and destroyed without compensation).
This has also been enforced by marketplaces like Amazon in recent years, as the GPSR states that marketplaces are responsible for ensuring that third-party sellers meet certain requirements. As such, Amazon has forced sellers to sign an EU AR agreement or have their products become unavailable in the EU.
What is the purpose of an EU authorised representative?
The primary reason this requirement exists in the first place is to ensure that there is someone reviewing compliance documentation before products are sold in the EU. This is a serious matter, as many products that do not meet EU safety standards and other compliance requirements are available for purchase online.
Second, this requirement also ensures that:
a. There is an EU contact point on the packaging
b. The market surveillance authorities can contact someone to ask questions about products failing to meet applicable requirements
Which products require an authorised representative?
The Market Surveillance Regulation does not provide a product scope or product list. Instead, Article 4(5) states that the EU authorised representative related provisions apply to the following regulations and directives, which in turn cover products within a defined scope.
| Regulation name | Product name/scope |
| Construction Products Regulation (EU) 305/2011 | Construction products |
| Personal Protective Equipment Regulation (EU) 2016/425 | Personal protective equipment |
| Appliances Burning Gaseous Fuels Regulation (EU) 2016/426 | Gas appliances and fittings |
| Noise Emissions in the Environment Directive 2000/14/EC | Equipment for use outdoors (machinery) |
| Machinery Directive 2006/42/EC | Machinery |
| Toy Safety Directive 2009/48/EC | Toys |
| Ecodesign Directive 2009/125/EC | Energy-related products |
| RoHS Directive 2011/65/EU | Electrical and electronic equipment |
| Pyrotechnic Articles Directive 2013/29/EU | Pyrotechnic articles |
| Recreational Craft Directive 2013/53/EU | Recreational craft and personal watercraft |
| Simple Pressure Vessels Directive 2014/29/EU | Simple pressure vessels |
| EMC Directive 2014/30/EU | Electrical and electronic equipment |
| Non-automatic Weighing Instruments Directive 2014/31/EU | Non-automatic weighing instruments |
| Measuring Instruments Directive 2014/32/EU | Measuring instruments |
| ATEX Directive 2014/34/EU | Equipment and protective systems intended for use in potentially explosive atmospheres |
| Low Voltage Directive 2014/35/EU | Electrical and electronic equipment |
| Radio Equipment Directive 2014/53/EU | Radio equipment |
| Pressure Equipment Directive 2014/68/EU | Pressure equipment |
Initially, this was primarily required only for products that require CE marking. However, as of 2024, the EU authorised representative requirement was extended to other consumer products as part of the General Product Safety Regulation.
As such, non-EU sellers of the following product need an authorised representative:
- Clothing
- Home textiles
- Children’s products
- Furniture
- Bikes
- Gym machines
- Other fitness equipment
- Other consumer products
Is an authorised representative required for CE marked products?
Yes, if your company is located outside the EU and you are selling products that fall within the scope of one or more CE marking directives listed in Article 4(5) to consumers, then you must have an authorised representative.
Note that the GPSR has extended the EU authorised representative requirement to other consumer products as well.
Where can I find an authorised representative?
There are many companies offering authorised representative services in the EU. For example, ProductIP offered a yearly service package for 2000 EUR. In addition, they also charge 225 EUR per hour if they need to act on behalf of a non-EU company, for example, when communicating with market surveillance authorities.
Here are some companies offering EU AR services:
- 24hour-AR
- QIMA
- ProductIP
- AR Experts
- Authorised Rep Compliance
- TerrainQ Market Access
- Authorised Representative Service
- Certification Company
- Obelis Group
- Earn
- GLOBALNORM
- CIRS
- Clever Representative
How much does an authorised representative cost?
The price differs between service providers. For example, here is the current pricing offered by ProductIP:
- Annual fee: 1800 EUR
- Hourly rate: 225 EUR
- Deposit: 2000 EUR
Note that these rates are subject to change and may already be outdated.
What kind of documentation is needed?
Here is an overview of documentation that may need to be submitted to the EU authorised representative:
Compliance documents
- Test reports
- Declaration of Conformity
- Technical documentation
- User instructions
- Product images
- Product labels
- Packaging artwork
Business license/company registration document
You must provide a business license or other evidence of incorporation. This differs depending on the country and jurisdiction.
Examples
United Kingdom: Certificate of Incorporation
Hong Kong SAR (China): Business Registration Certificate
Product liability insurance
You may also need product liability insurance. You can find a list of companies on this page.
EU AR Agreement
You will need to sign a service agreement with the authorised representative stating the following:
- Service scope
- Covered products
- Terms
- EU AR responsibilities
- Service fees
Do EU based companies need an authorised representative?
No, EU based companies are commonly defined as either manufacturers or importers and are therefore also defined as economic operators.
Can non-EU companies act as authorised representatives?
No, that would defeat the entire purpose of having an authorised representative in the first place.
Can non-EU companies set up entities in the EU instead of using an authorised representative?
Yes, it is possible to set up a company in an EU member state that acts as the importer. As mentioned in Article 4 of the Market Surveillance Regulation, EU importing companies can act as economic operators.
However, doing so does not exempt you from ensuring compliance with applicable EU regulations and directives. It is just another way to satisfy the requirement to have an economic operator inside the European Union.
Do UK companies need an EU authorised representative?
Yes, as the United Kingdom is no longer an EU member state, UK companies cannot act as economic operators in the EU. As such, UK-based companies selling B2C to consumers in the EU need an authorised representative there.
Do we need an authorised representative if we sell to businesses in the EU?
No, if you sell to a business instead of a consumer, then the EU company is likely the economic operator. This means that the EU company is primarily responsible for ensuring compliance.
For example, a Chinese manufacturer selling OEM or ODM products to a company in Germany would not need an EU authorised representative.
Hi Fredrik,
I am an artist based in the UK and make original paintings- will I need a representative if I sell to a customer in the EU or NI
Thanks
This was a really helpful article thank you. Will it be updated with a new list of products covered when the new GPSR come into force. I sell digital products and am interested to know which digital products will be covered.
Hello Fredrik,
I find your articles are really useful.
I am an Asian seller who sell products from my country and other products from Asia in EU. I am a Reseller, I could not get any document or authorised representative document from the owner. What should I do ?
Hell Fredrik,
I have a question and hope you can help. Im not particularly certain if I need a EU rep so hoping you can assist. I have a US company that sells products in Poland. Our supplier is based in china and ships the product DDP to a fulfillment partner inside of Poland who houses and fulfills the products on our behalf, whenever we get an order via our website. We sell pet products and electronics. Is an EU rep necessary in my case? our supplier is handling the importation process.
Hello Fredrik
My company is non-EU.
1) Is it possible for me to appoint a very close friend of mine based in the EU as EAR?
2) Where do we report the agreement we made between ourselves? How will it be determined that he is my company’s EAR?
How does this process work?
I can’t thank you enough for providing us with such great content.
Hello Uğur,
I am not aware of any such arrangement so I cannot say.
Hello Fredrik,
If a HK based company is buying from a manufacturer in Spain and selling B2C to consumers in France via Amazon, the HK company is required to add EC REP logo ? Thanks in advance.
Hi Fredrick,
Thank you for this article.
Can you please quote the clause in which the authorised representative is enforced?
Hi
We have a branch in the Netherlands called Timesource Ltd – Netherlands Branch but has no employees. Can the CEO of the UK company be the Responsible person?
regards
John
Hi John,
Is this the company importing the products (e.g. B2B) into the EU or are you selling B2C from the UK to the EU?
Hello Fredrick,
Thanks for your articles they have been very helpful.
I have a few questions that I need more clarification. I will list them here but first a quick overview:
Summary:
My company is based in the UK and we are signed up with Amazon FBA UK to sell only in the UK marletplace and we plan to launch a product in the “Toys and games” category.
We have read the Toys directive regulations for the UK and have made sure our product complies to all the requirements. However Amazon still dont approve.
Could you please help me on the following points:
1. Why do I need an EU representative if my company is based in the UK and we only plan to sell in the UK marketplace?
2. For markings on packaging we have got our supplier to prepare the conformity tests for UKCA marking and CE marking. We have also added to 0-3 age restriction logo on our product packaging. Are we missing any other markings for our product.
3. If we need a UK representative for our toy product where can I find this? Or can I put myself as a UK representative?
4. I get my supplier from China to make the products and send to amazon FBA warehouse. What information would I need on my product packaging for selling toys?
Hi Emded,
1. I don’t think you need an EU AR in that case. But, my understanding is that the UK will also implement their own AR requirement.
2. I cannot say that based on the information you provided. You should contact a lab.
3. We don’t have a list of UK ARs at this point
4. Same as question 2.
Hi,
I am UK based FBA seller in electronics category, we only cater to UK MARKET and do not list our products in EU countries, do we still need to declare a EU representative?
Hi Aaron,
Not if you don’t sell in the EU or ship to consumers in the EU.
What if your product needs CE marking but you only sell in UK?
My understanding is that the CE mark is still required for some products in the UK. I don’t think they dropped all safety and compliance requirements overnight when they left the EU.
UK moved to the UKCA Certification framework, check the exact requirements with local authoryties
Hello Fredrik,
Thanks for your articles!
We want to sell toys on Amazon.co.uk and we’ve signed up UK authorized representative, however we still received the email from Amazon following:
Hello from Amazon Selling Partner Support, Thank you for your application to sell [Toys] products. We’ve reviewed the documentation you provided and determined that it does not meet the following reasons:
File Name: [Product Packaging Picture]
• [The images provided do not meet the EU labelling guidelines, which state that address on the label must be in an EU country. Please provide product images that meet this requirement.]
Now I’m wondering that an EU address is necessary even if Brexit?
What’s your suggestion?
Thanks!
Hi Auggie,
That depends. Are you selling to Amazon in the UK or the EU?
If the EU then you’ll need an EU AR, not a UK AR.
Hello Fredrik,
I find your articles are really useful.
We are based in UK and selling licensed product in UK and EU. Most of EU sales are through our distributors. Do we still need EU AR? My understanding was if we are selling the product through the distributors, they will be act as AR as importer?
Also we are selling our product through Amazon and I guess We will need AR for Amazon sales as this is B2C?
Thanks
Hi Ji,
My understanding is that this does not impact EU importers, as they are already responsible. ProductIP.com also made it clear that an importer in the EU cannot appoint an AR.
So, if your distributors are importing the product into the EU then this would not apply to them.
Yes, Amazon has more info about that on their page. There is a link in the article.
Hi Fredrik,
Is there a requirement to put any logo next to the EU Rep address on the packaging? For example, I have seen a “EC REP” logo that must be placed on medical devices, but I’m not sure if this applies to all types of products (we make pyrotechnics category F1, which are also CE marked). Is it enough to just put EU AR + address?
Thanks
Hello Joanna,
For medical devices, this has been a requirement much longer. I have not heard of any EU REP logo yet.
It´s not a logo it´s a labeling symbol consisting in the EC and the REP inside 2 boxes followed by this figure details. You can search in google for EC REP symbol and look at the pics as example. If the products are CE marked and you are not the selfdeclared manufacturer it should be in place.